Appendix F: Information Sources Containing Data Subsets, but not Comprehensively Comparable Alternatives to TRI

APPENDIX F
INFORMATION SOURCES CONTAINING DATA SUBSETS, BUT NOT
COMPREHENSIVELY COMPARABLE ALTERNATIVES TO TRI DATA

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Appendix F: Information Sources Containing Data Subsets,
But Not Comprehensively Comparable Alternatives to TRI Data
In this appendix, data elements available from several information sources are compared to those reported to TRI. The analysis is
broken down by the specific types of data collected under TRI. While some sources may appear to be substitutes for TRI, they do not
adequately address the entire scope of TRI, even in combination. For example, a given source may:


Not include all toxic chemicals covered by TRI,



Be compiled less frequently than TRI, and/or



Not be as easily accessible (if at all) to the general public.
Table F-1: Relevant Information Sources
(TRI Included for Comparison)
Description

TRI DATA
EPCRA §313 requires facilities to submit
reports on releases (including disposal) of
particular toxic chemicals exceeding a given
threshold. The reports provide information
on the quantity of chemical released into the
environment and to which medium (air,
land, water) the disposal took place, as well
as information about waste management and
the amount of chemicals stored on-site.

Chemical
Coverage
The current TRI
toxic chemical list
contains 595
individually-listed
chemicals and 31
chemical categories
(including four
categories
containing 68
specifically-listed
chemicals).

Industry/Facility
Coverage
NAICS codes
corresponding to SIC
codes 20-39, 10; 12;
4911, 4931, 4939; 4953;
5169; 5171; and 7389.
A facility need only
report if it has 10 or more
Full Time Equivalents
(FTEs).

2

Reporting
Frequency
Annual.

Public Access
EPA compiles the TRI data and
makes them available through
several data access tools, including
TRI Explorer and Envirofacts.
Other organizations also make the
data available to the public through
their own data access tools.

Description

Chemical
Coverage

AIR EMISSIONS (SECTIONS 5.1 AND 5.2)
National Emissions Inventory (NEI)
NEI provides estimates of anthropogenic
8 CAPs and 187
pollutant emissions from stationary sources, HAPs.
as well as area sources and mobile sources.
These estimates, submitted to EPA by
delegated authorities (state or county),
electric utilities, and/or generated by EPA
from various sources, differ in estimation
methodology used.
Air Facility System (AFS)
AFS contains compliance and permit data for N/A
stationary sources of air pollution regulated
by U.S. EPA, and state and local air
pollution agencies.

State Air Emissions Inventories
Several states and regional agencies
maintain their own air emissions inventories.
However, the amount of data as well as the
types of data elements collected vary widely
from state to state.
Title V Part 70 Operating Permits
Under the 1990 Clean Air Act Amendments,
facilities designated as "major sources" and
facilities otherwise subject to §112 and Title
V must apply for a Title V Part 70 Operating
Permit. As part of the application for a Title
V permit, some facilities may have to report
emissions of air toxics.

Industry/Facility
Coverage

Reporting
Frequency

Public Access

No NAICS limitations.

Triennial.

CSV files can be downloaded from
EPA’s Web site.

No NAICS limitations.

Annual.

Can be accessed on a facility-byfacility basis through EPA data
access tools, including Envirofacts
or the Enforcement and
Compliance History Online
(ECHO).

Varies widely (e.g.,
the California Air
Resources Board
maintains its own
list of about 400
toxic air pollutants).

Varies.

Varies.

Most of these data are submitted to
NEI. Some data are available on
the Web on a state-by-state basis.

187 HAPs.

No NAICS limitations.

At the time of
permit
application,
renewal, and
modification—
permits are
typically renewed
every 5 years.

No central repository for the
information.

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Chemical
Industry/Facility
Reporting
Coverage
Coverage
Frequency
DIRECT DISCHARGES TO WATER (SECTION 5.3)
Integrated Compliance Information System–National Pollutant Discharge Elimination System (ICIS-NPDES)
ICIS-NPDES is a national information
Contains monthly
No NAICS limitations.
Major permittees
management system that tracks
discharge
must submit
implementation of the National Pollutant
monitoring data for
Discharge
Discharge Elimination System (NPDES)
selected water
Monitoring
program, authorized by the Clean Water Act. parameters/pollutant
Reports (DMRs)
ICIS-NPDES tracks permit issuance, permit s and flow rates for
monthly or
limits, self-monitoring data, compliance data all CWA major and
quarterly; nonand other data pertaining to facilities
many minor
major permittees
regulated under NPDES.
sources.
must submit at
least annually.
Description

4

Public Access

Can be accessed on a facility-byfacility basis through EPA data
access tools, including Envirofacts,
and ECHO.

Chemical
Industry/Facility
Reporting
Coverage
Coverage
Frequency
UNDERGROUND INJECTION AND LAND DISPOSAL ON-SITE (SECTIONS 5.4 AND 5.5)
RCRA Biennial Reports
Section 3002(a)(6) of the Resource
Contains annual
No NAICS limitations;
Biennial.
Conservation and Recovery Act (RCRA)
volumes of RCRA
however, certain waste
requires EPA to develop a program for
wastes and how
categories are excluded
hazardous waste generators to report the
they are managed
(e.g., mining and
nature, quantities, and disposition of
(offsite in the case
agriculture).
hazardous waste generated at least once
of Large Quantity
every two years. In addition, section
Generator and on3004(a)(2) of RCRA requires treatment,
site in the case of
storage and disposal facilities (TSDFs) to
treatment storage
submit a report on the wastes that they
and disposal
receive from off-site. The biennial
Facilities, TSDFs).
Hazardous Waste Report (also known as the Each waste stream
“Biennial Report”) was implemented in
is characterized by
1985 to comply with these requirements.
all applicable waste
The Biennial Report form (8700-13A/B)
codes but volumes
must be submitted to the authorized state
of each are not
agency or the EPA Regional Office by
broken out.
March 1st of every even-numbered year.
The form includes information such as the
facility's RCRA ID number, the name
and address of the facility, the quantity of
hazardous waste sent to each TSDF in
the United States and the manner in which
the waste was treated during the previous
Description

Public Access

Can be accessed on a facility-byfacility basis through EPA data
access tools, including Envirofacts.
Text files can be downloaded from
EPA’s Web site.

year.
DISCHARGES TO A POTW (SECTION 6.1)
RCRA Biennial Reports (BR)
Biennial Reports require some reporting of
See above.
discharges to POTWs. See above for more
details.
ICIS-NPDES

See above.

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See above.

See above.

Description

Chemical
Coverage
See above.

Industry/Facility
Coverage
See above.

ICIS-NPDES allows for reporting of indirect
discharges to water. See above for more
details.
TRANSFERS TO OTHER OFF-SITE LOCATIONS (SECTION 6.2)
RCRA Biennial Reports (BR)
Biennial Reports contain hazardous waste
See above.
See above.
data from large quantity generators and
TSDFs. Biennial Reports also require
reporting of off-site transfers on Form GM.
Information includes the RCRA ID of the
facility to which the waste was shipped, the
processes used to treat, recycle, or dispose of
the waste at the off-site facility, the off-site
availability code, and the total quantity of
waste shipped during the report year. The
reports also provide data on the volume of
hazardous waste shipped off-site for land
disposal, a release end-point of relevance to
TRI. See above for more details.
CHEMICAL STORAGE AND INVENTORY DATA (SECTION 4.1)
EPCRA §312 Tier I and II Reports
Hazardous or
No NAICS exemptions
EPCRA §312 requires that states establish
extremely
for facilities that are
plans for local chemical emergency
covered under the
preparedness and that inventory information hazardous
substances
reporting threshold
on hazardous chemicals be reported by
(essentially any
requirements, but
facilities to state and local authorities.
substance that poses facilities not included
a health or physical under OSHA’s Hazard
hazard).
Communication Standard
(e.g., mines) do not have
to file.
Risk Management Plan (RMP)

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Reporting
Frequency
See above.

See above.

See above.

See above.

Annual.

On a facility-by-facility basis, by
forwarding a written request.

Public Access

Description
Under the authority of section 112(r) of the
Clean Air Act, the Chemical Accident
Prevention Provisions require facilities that
produce, handle, process, distribute, or store
certain chemicals to prepare a Risk
Management Plan (RMP) and submit the
RMP to EPA. These plans include
information about chemical amounts stored
and processed at RMP facilities.
Chemical Data Reporting (CDR)
Under TSCA Section 8(a), chemical
manufacturers (including importers) are
required to report manufacturing-related
information to EPA for sites that
manufactured (including imported) 25,000
pounds or more of a reportable chemical
substance any one calendar year between
submission periods. Industrial processing
and use information and commercial and
consumer use information must also be
reported for these sites.

Chemical
Coverage
Certain flammable
and toxic
substances.

Industry/Facility
Coverage
No NAICS limitations.

Reporting
Frequency
At least every
five years, or
within six months
of an incident.

Varies.

Limited to manufacturers,
including importers, of
subject chemicals.
Certain manufacturers are
exempt, including small
manufacturers (sales
<$40 million), those
manufacturing a chemical
for research and
development, those
manufacturing chemicals
as impurities, and those
submitting information
under another TSCA
Section 8a rule.

Every four years.

Data claimed as Confidential
Business Information (CBI) are not
available to the public. Non-CBI
data downloads are available from
EPA’s CDR website.

See above.

See above.

POLLUTION PREVENTION DATA (SECTIONS 8.1-8.7; 8.10)
RCRA Biennial Reports (BR)
Biennial Reports contain pollution
See above.
See above.
prevention information on hazardous waste
from large quantity generators and TSDFs.
Data are collected primarily by states, and
are collated by EPA. See above for more
details.
State Environmental Agency Databases

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Public Access
Restricted access: RMP
information may be accessed via
the Federal Reading Rooms.

Description

Chemical
Coverage
Varies.

At least fourteen states1 implement
mandatory pollution prevention programs.
Pollution prevention data collected under
these programs varies by state, and may
include both data similar to that collected by
TRI (e.g., quantities of waste managed,
source reduction activities, etc.) and details
not found in TRI (e.g., pollution prevention
plans, costs associated with waste
management, etc.).
EMERGENCY RELEASE DATA (SECTION 8.8)
National Response Center (NRC)
NRC collects real-time information about
Oils and chemicals.
virtually all oil and chemical spills
throughout the United States to identify
spills for which to coordinate emergency
response.
Risk Management Plan (RMP)
RMP contains a five-year accident history
See above.
for each facility with details on releases of
regulated substances from covered processes
with 1) on-site deaths, injuries, or significant
property damage; or 2) known off-site
deaths, injuries, property damage,
environmental damage, evacuations, or
sheltering in place. See above for more
details.

1

Industry/Facility
Coverage
Varies. May include TRI
filers, facilities that use
toxic chemicals, and
generators of hazardous
waste.

Reporting
Frequency
Varies.

No source exemptions.

Real-time.

Historical information about spills
can be retrieved through the NRC
online query system:
www.nrc.uscg.mil/foia.html.

See above.

See above.

See above.

Public Access
There is no central source for state
collected pollution prevention data.
Accessibility varies by state.

Arizona, California, Georgia, Maine, Massachusetts, Minnesota, Mississippi, New Jersey, New York, Oregon, Tennessee, Texas, Vermont, and Washington.

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Description

Chemical
Coverage

STATE RIGHT-TO-KNOW PROGRAMS
Several states require expanded state TRI
Varies. Often
reporting to include industries or facilities
identical to TRI.
not covered by TRI or to report information
beyond that required by the federal TRI
Program (e.g., Arizona, Massachusetts, and
Wisconsin).

Industry/Facility
Coverage
Varies. May include more
industries than TRI.

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Reporting
Frequency
Annual.

Public Access
There is no central source for state
collected data. Accessibility varies
by state.

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